Also known as: collateral estoppel · collaterally estop · estopped collaterally · issue preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A procedural doctrine that bars a party from relitigating an issue of fact or law that was actually litigated and necessarily decided in a prior action between the same parties or their privies. The doctrine applies once a court of competent jurisdiction has rendered a valid and final judgment on the issue. It promotes judicial efficiency and protects parties from the burden of repeated litigation on settled matters.
Connor Clark stood trial for robbing one victim during a poker game and the jury acquitted him after identity became the sole contested issue. The state then charged him with robbing a second victim from the same incident. The acquittal prevents the state from retrying the identity question in the second prosecution.
Caitlin Crowley was acquitted after a jury determined she was not the person who committed the charged act. The state later brought a new case relying on the same identity question even though additional evidence had surfaced. The earlier acquittal precludes relitigation of that ultimate fact.
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Copperfield Mining lost an SEC enforcement action that found its proxy statement materially false. A private shareholder then sued the company for damages arising from the same statement and moved for summary judgment on the falsity element. The prior judgment supplies that element in the shareholder suit.
Cobalt Energy financed and directed every strategic decision in a carrier's challenge to a port fee schedule. After the carrier lost, Cobalt Energy filed its own refund action raising the identical methodology question. The earlier determination binds Cobalt Energy because it controlled the first litigation.
Corinne Cho sued a federal agency over wildlife-protection rules and lost on standing grounds. Defenders of Wildlife later brought a separate challenge to the same rules. The prior standing dismissal does not estop the new plaintiffs because they were not parties or privies to the first suit.
Canyon Construction lost an arbitration that decided the meaning of a key contract clause. It later filed a federal suit against the same counterparty seeking to relitigate that clause. The arbitration award estops Canyon Construction from reopening the already decided contractual issue.
A plaintiff may invoke offensive nonmutual issue preclusion when the prior judgment resolved the identical issue after a full and fair opportunity to litigate and when fairness to the defendant supports application of the doctrine. Courts weigh factors such as the defendant's incentive to litigate vigorously in the first action, procedural differences between the two proceedings, and the risk of inconsistent judgments.
An acquittal bars the later prosecution when identity was the only rational issue in the first trial and the second charge rests on the same factual determination. The Double Jeopardy Clause incorporates collateral estoppel and prevents the state from relitigating an ultimate fact already resolved in the defendant's favor.
A nonparty is bound when it assumed control over the prior litigation and possessed a direct financial or proprietary interest in the outcome. Once an issue is actually and necessarily decided by a court of competent jurisdiction, that determination becomes conclusive in later suits involving the controlling nonparty.
…and in litigation to which the other agencies are not parties. As for the contention that the other agencies will be "collaterally estopped" to challenge our judgment that they are bound by the Secretary of the Interior's views, because of their participation in this suit, post , at 596-597: Whether or not that is true now, it…